Correspondence 0001213900-25-019156 from Franklin BSP Capital Corp (FRBP) (CIK 0001825248) (FRBP)
Franklin BSP Capital Corp (FRBP) (CIK 0001825248)
Date: March 3, 2025 · CIK: 0001825248 · Accession: 0001213900-25-019156
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-284271
Letter
VIA EDGAR Division of Investment Management Washington, D.C. 20549 Attn: Christina DiAngelo Fettig and David Mathews Re: Franklin BSP Capital Corporation Form N-14, File No. 333-284271
Dear Ms. DiAngelo Fettig Mr. Mathews:
On behalf of Franklin BSP Capital Corporation (the “Company”), we are providing the following response to a comment received via telephone from the staff of the Securities and Exchange Commission (the “Commission”) on February 28, 2025, relating to the Company’s Registration Statement on Form N-14 filed with the Commission on February 21, 2025 (the “Registration Statement”). Please note that all page numbers in our response are references to the page numbers of the Registration Statement.
Senior Securities
1. With respect to the secured borrowings of the Company as disclosed on page 45 of the Registration Statement, please confirm that the Company is a limited derivatives user as described in Rule 18f-4(c)(4) and that the Company has excluded such derivatives transactions for purposes of computing asset coverage as permitted by Rule 18f-4(b).
Response: The Company confirms that (i) it is a limited derivatives user as described in Rule 18f-4(c)(4) and (ii) the secured borrowings as presented on page 45 of the Registration Statement comprise financing amounts in respect of assets which underlie the Company’s total return swaps, which have been excluded from the calculation of asset coverage as permitted by Rule 18f-4(b).
* * * * *
NEW YORK BEIJING Boston HONG KONG HOUSTON LONDON LOS ANGELES PALO ALTO SÃO PAULO TOKYO
Securities and Exchange Commission
March 3, 2025
Please do not hesitate to call Rajib Chanda at (202) 636-5543, Jonathan Pacheco at (202) 636-5876 or me at (202) 636-5592 with any questions you may have regarding this filing or if you wish to discuss the above responses.
Very truly yours,
/s/ Steven Grigoriou
Show Raw Text
CORRESP
1
filename1.htm
Simpson Thacher & Bartlett LLP
900 G Street, NW
Washington, D.C.
20001
telephone: +1-202-636-5500
facsimile: +1-202-636-5502
Direct Dial Number
(202) 636-5592
E-mail Address
steven.grigoriou@stblaw.com
March 3, 2025
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attn: Christina DiAngelo Fettig and David Mathews
Re: Franklin
BSP Capital Corporation
Form
N-14, File No. 333-284271
Dear Ms. DiAngelo Fettig Mr. Mathews:
On
behalf of Franklin BSP Capital Corporation (the “Company”), we are providing the following response to a comment received
via telephone from the staff of the Securities and Exchange Commission (the “Commission”) on February 28, 2025, relating to
the Company’s Registration Statement on Form N-14 filed with the Commission on February 21, 2025 (the “Registration Statement”).
Please note that all page numbers in our response are references to the page numbers of the Registration Statement.
Senior Securities
1. With respect to the secured borrowings of the Company
as disclosed on page 45 of the Registration Statement, please confirm that the Company is a limited derivatives user as described in
Rule 18f-4(c)(4) and that the Company has excluded such derivatives transactions for purposes of computing asset coverage as permitted
by Rule 18f-4(b).
Response: The Company confirms
that (i) it is a limited derivatives user as described in Rule 18f-4(c)(4) and (ii) the secured borrowings as presented on page 45 of
the Registration Statement comprise financing amounts in respect of assets which underlie the Company’s total return swaps, which
have been excluded from the calculation of asset coverage as permitted by Rule 18f-4(b).
* * * * *
NEW YORK
BEIJING
Boston
HONG KONG
HOUSTON
LONDON
LOS ANGELES
PALO ALTO
SÃO PAULO
TOKYO
Securities and Exchange Commission
March 3, 2025
Please do not hesitate to call Rajib Chanda at (202) 636-5543, Jonathan
Pacheco at (202) 636-5876 or me at (202) 636-5592 with any questions you may have regarding this filing or if you wish to discuss the
above responses.
Very truly yours,
/s/ Steven Grigoriou
Steven Grigoriou
cc:
Rajib Chanda, Simpson Thacher & Bartlett LLP
Jonathan Pacheco, Simpson Thacher & Bartlett LLP